Document x1RLeq090Z1ywRVOB05MX4pdg

VCM Plant April 5, 1977 Conoco Chemicals Continental Oil Comoany P.O.Box 605 Westlake. Lcursiana 70669 (318) 882-0550 4/. V- ] njd Mr. Paul Fahrenthold, Chief Engineering Section Air Compliance Branch United States Environmental Protection Agency First International Building 1201 Elm Street Dallas, IX 75270 Dear Mr. Fahrenthold: With reference to your letter related to release of information from our file under the Freedom of Information Act, I have been in touch with Mr. G. Bernath by phone and indicated to him our desire to review this information before release. We intend being at your office on April 7, 1977 on another matter and will take this opportunity to review our file at that time. Mr. Bernath has indicated he will have the file available for review on this date. Sincerely 0. A. DeBernardi Manager - VCM Plant Westlake, La. br I 75 Beginning Another Century of Service -- With Energy VVC 000020098 ENVIRONMENTAL. PROTECTION AGENCY APR 0 1 1977 f-'-\ C/ f "O w Hr. John li. UcCullc-y Continental Oil Company P. 0. Pox COS Ucstlakc, Louisiana 70CC9 Dear Hr. HcCulley: Your Totter of Larch I, 1277, raoucstinq clarification as to this officers enforcement policy renaming excess emissions due to n:a Ifunc tion of equipment, lias been received. This is to inform you that there are no provisions for excess emissions during startup, shutdown, emu malfunction. Gur enforcement policy is not based on a "strict interpretation" of the regulations; it is nos based cn any interpretation at all. Rather, we are adhering to the policy which is explicitly expressed in the preamble to the vinyl chloride rO'iul ati or.s In the* nreuiiiole, it is stated I:,.:e do not belle/e plants should be allowed to emit excess emissions during malfunction, and therefore are requiring them to shut down immediately.*' This is based on the fact that vinyl chloride has been implicated as the causal scant of cir.pionarcoma and other serious disorders, both carcino genic cr.ci r.on-cercinogenic, The purpose of Cr.Vs regulations is to ciuriw.iza vinyl chiorice emissions into the ambient air and thereby minimize the health risks of tka people living in the vicinity of those plants. expressed in the preamble (quoted in part above), LRA did consider whether to incorporate a provision -for excess emissions during start-up, shutdown, and malfunction. In light of the significant health consequences which ray result from re-occurring malfunctions, the fnoncy does not Loleivo plants should be allowed to emit excess emissions during malfunctions. Unless back-up controls arc available, the Agency will require tha subject source to shut down Immediately. Until and unless the regulation is amended, this will remain our policy. Should you have any questions concerning this, you may contact .Ur. Gary Bernal!] of my staff by telephone at (214) 749-7075. ITMIIOL > | BURK A Me ;> . . Sincerely, ORIGINAL SIGNED BY O. W. LIVELY, JRj FOR Howard G. Pargman Director, LnvGrcemcnt Division Gi. v*-"" 5AEA:GABcrnath:jeb:X7675:3/28/77 _Cd Reich, ^.V _jlY j FAr<Ai^Old . iv'jk ;\ | Director, DStS^cuRf?Nccs 6AEL>M/ Col 1i 1-3K?-? ' {PA FOHM 13:10-1 VVC 000020099 OFFICIAL FILE COPY NOV 20 Mr. Jack Cearley Mx. John McCulley Conoco P. O. r=o:: G05 Westlake, Louisiana 70669 Gentlemen: Enclosed is a major portion of a document authored by the Washington office of the Environmental Protection A.crencv for the Regional offices to use as an aid in implemontircr the vinyl chloride regulation?. This document dons not have tne force of lav? and is boinc sent to you riorolv for your aid and information. It does respond to several topics discussed during the meeting held at this office on November 19, .1976. Sincerely, Dennett Stokes Attorney Enforcement Division Enclosure^ 6AEA:BStokt?s:sme:X7675:11/24/76 300-15 tvuauL ; tUKNAUC | 0<TC Jto ; ti>K KOHU 132Q-1 CONCURRENCES ....................-............................. ---- ................................--- OFFICIAL FILL CORY WC 000020100 ENVI 7NMENTAL PROTECTION AG' ICY } L A *-/ (iU^ ^ *4* 12 1976 CERTIFIED MAIL: RETURN RECEIPT REQUESTED (489984) Continental Oil Corxany T\ 0. Pom C05 Woatlako , Louisiana 70669 Hoar Sir: As you nay already bo aware, the. Motional lir-ienion fitar^ard for the J'azardous /ir Pollutant vinvl chloride v:as prcrvlcrtpr. on October 01, 197C. (Cory enclosed) Is an affected. Locilitv you will ,o-3 rood roe. to bo er-eratinrr 5.n ccr.'pl lance with the omission standard, cr be operating subject to ar approved waiver of ccrpiianco, within 90 davs of the. off. ochive cate, or by January 21, 1977* This is to advise you that if you feel that your facility can operate in cc--.nliarro v7ith the ^mission standard, 'rou are ro~ cuiirad to conduct pc-rfor.r.anca tests in accordance with the tost procedures pro^rIratcd under Section Ll.r-7, r. o later than January 21, 1977. r. ho Lection also rr.ruires that you provide this office at least SO days notice prior to the tests so v'e may have an observer present. If your fncilifv cannot operate in si on stnncr.rds by J - unary .71, 1977 of compilerce in accordance with P tart that such a waiver be arelied you ray be assured that bv January operating under an approved vaiver days for such review. cemliarce v:ith tho r?ri?'Ts rav iv.orTv for ' a vaivor ction dl.ll. It is irpnr** for in. a tirolv rsrr.cr so 71, 1977, vou will be "his office is a]lovof CO Although this letter is beir.c sent to ' ssist you in cor.nlyir.r with the lew, vov are cf course charno: with the bu'.ov'l.odcn of the rrquirc'cr.tr. of the law and of the ape]icable reculatiors upon their publication. .6AFA :GABernath : sne:X7675 :11/5/76 i(Y 100-42 ENVr OMENTAL PROTECTION AG ICY Should you have any cruestionn concorrinc? this, you ray contact *'r. Carv r,':r?;ath of nv ctnif hy letter to this offics or by telephone et (?14) 749-7675. Sincerely, 0. V\ Lively Acting Director Enforcement Division enclosure i ftYMROL f UIINAUC DVTC l-TA FORM | 320-1 CONCURScNCES Vvc 0&CLl OFFICIAL. FILE COPY ENVIRONMENTAL PROTECTION A<-----NCY o s ::ov 1376 Continental Oil Company P. 0. Bo;: C05 Westlake, Louisiana 70669 Dear Sir: You arc probably aware that regulations wore promulgated on October 21, 1976, which require control of emissions cf vinyl chloride. (-'1 Pc-dor el Register 4C560) . It is our understanding that your plant' ray-be subject to those reg ulations, and V7e have already sent copies of the regula tions to your plants In part because of the complexity of plants which omit vinyl chloride, the regulations are complex. In addition, new roauiatic-ns usually create many questions of interpre tation. t:o believe that a meeting between ITA and the industry to discuss those new regulations would be helpful to both of us. We propose that a meeting be held between FPA v/orkincr-levol technical and legal personnel and industry technical and. environmental personnel who will bo working with the ref lations. Although there is a significant number of plants in the five state region in which we work, wo believe that the mooting could bo kept small enough to have some general discussions of problems as well as answering specific ques tions of interest. In order to have the iraxiruir; number of FPA personnel available to respond to cuostions, we believe that such a meeting could beet bo held in Dallas. V'e arc therefore scheduling a mooting on the vinyl chloride regulations for Friday, Vovorber 19, 1976, to begin at 9 *-00 A.'!, in our offices on the 29th floor of the First Interna tional Fuilding, 1201 kin Street, Fallas, Texas. If one or GAEA:BStokes:sne:X7675:11/8/76 300-11 \ ________________________________________________________________________ CONCURRENCES VHDOL J> ultNAMC P*T J>- CPA FORM 1.120-1 OFFICIAL FILE COP ENVIRONMENTAL PROTECTION AGENCY ' -' -- , -o^'O/ FEB 28 1377 -i Hr. J. A, DeBernardl Continental Oil Company P. 0. JOX O'Jb Westlake* Louisiana 70569 Dear Mr. Oc&arnardl: Your waiver request package dated December 21, 1975, has been received and evaluated. This Is' to inform you that v:e cannot complete our evaluation until you submit additional infarction relative to your waiver request- Generally, you have not Identified which portions cr particular paragraphs of the vinyl chloride regulations for which ycu arc in need of a waiver, `..'a cannot issue a general waiver for the entire vinyl chloride regulations. 'Additionally, you have not adequately icenrified each piece of equipment, vent, or stream, for which you are in need of a waiver. Your response to the items listed in the attachment will enable us to finalize the review of ycur recuest. Should you have any questions ccr.cerniiv; tins you i;;ay contact either Gary fcernath.or Martin Brittain by telephone at (214) 749-7675. Sincerely, Paul D. Fahrsnthold Chief, Engineering Section Air Compliance branch Attachment cc: Louisiana Air Control Connissicr. P. 0- oox ooooO Mow Orleans, Louisiana 701 CO TMOL > >lUKNXUI DAT* > bcc: Rich Biondi, DSSE Susan Wyatt, ESED 6ASA *7k/zs/? ? 6AEA:GA5ernath/MEBrittain:,ieb:X7675:2/25/77 CONCURRENCES ^nn0^0l4 OFFICIAL FILE COPY ENVIRONMENTAL PROTECTION AGENCY Items Relating to Via Ivor Eecuest Waiver request relating to the six emission points v\ A* For each emission point that is In need of a walver^pt-Gasa, - Identity the particular paragraph of the vinyl chloride regulations "t for which you are requesting a vtaiver. ^vT\\ f\\ B. Please enumerate and identify c-ach For example, enumerate and identify each EDCX* Inprocess wastewater stream, and each EDC ^tx/eT;issicn points. ventv each 'tank. Waiver request relating to the fugitive emissions A. As above for each fugitive emission area. Identify the particular paragraph of the regulations for which you are requesting a waiver. B. Please enumerate and identify each Damp, compressor, relief valve, and all equipment in VC service for which a waiver is being requested. Waiver request relating to emission testing You have requested a waiver of amission testing (even though you used the term waiver of compliance) `for all the YCn amission points regulated by the Rational Emission Standard for Vinyl Chloride.'' This is to inform, you that this office will only grant such a testing waiver for these particular prcc esses v:hich have been granted a waiver of compliance. For those sources a nd processes tnat you reel are presently In compliance, appropriate tosti r.g must be performed at a date which this office will require. If th ere are any suen sources in compliance which require testing, we v/ill talk with you in the near future to set up a testing date. As to your proposal to conduct the four emission tests in October, 1970, rather than scneduls four separate tests between February, 1970, and October, 1970, we are agreeable to such a schedule. >IYMDOL IUKNAME DATTT > tPA I'OKM 13ZO-1 CONCURRENCES OFFICIAL FILE COP't VCM Plant i March 1, 1977 - * ** 0 Howard 6. Bergman Director, Enforcement Division Region VI, Environmental Protection Agency First International Building 1201 Elm Street Dallas, U 75270 Conoco Chemicals Continental Oil Company P.O. Do*C05 Westlake, Louisiana VCG69 (316) 882-G5SO-- W-san. ri t Dear Mr. Bergman: Methods to comply with EPA's vinyl chloride standard at CONOCO Chemicals' VCM Plant depend on how EPA plans to assure compliance with it. We can imagine several different compliance strategies depending upon which directicn EPA moves. Each of these we believe obtains the necessary control but with significantly different costs. To try to obtain efficient emission control for the dollars spent, we would like to compare for you two of these strategies and point out the widely different cost per volume of vinyl chloride controlled. We hope to encourage EPA to adopt a control strategy that lets us install the more cost effective control system. Our more cost effective strategy envisions ^installation of one high quality thermal incinerator* V *When'~bperating as designed, we believe this unit will keep vinyl chloride emissions wall below permissible amounts. Industry experience teaches us that chemical process equipment, no matter how well constructed or operated, sometimes break dowru _ fL..e.xec^ this to be true with our vinyl chloride incir.eraticr>;tiirin.."*. ` " 5.>( ,_T___ K . , , /j fewii. ^_______. . X "IT . ^ ___fLj.S.S lciioug*n we are trying to outain absolute reiiaci1 tty or our control train maiiunction we would like to develop an understanding with EPA to continue to produce vinyl chloride and minimize production losses during the control device malfunction. We believe the small additional emission of vinyl chloride above the standard would not cause an unacceptable risk to public health and the environment. If EPA insisted that we immediately shut down the plant when our vinyl chloride train malfunctioned CONOCO-would he forced to avoid tho/blanket :dolrlcr-s/ci3V--. ofrl'osVproduction by installing a standby control system ;0nlyjn-this- fashion could we minimize our -losses cue cu.u ty w i tn thp^stricL-lntccp.retation. Installing the dual system we be!ieve represents 3 grossly disproportionate cost to control the small additional vinyl chloride emission during brief periods of plant operation during the main control device V Beginning Another Century of Service -- With Energy YJ/r